Privacy Notice

Last updated May 16, 2025

This Privacy Policy (“Policy”) describes how dYdX Operations subDAO and its affiliates (the “Ops subDAO” “we,” “our,” “ours,” and “us”) may collect, process, use, store and disclose personal information as data controller, and your rights and choices regarding this information. For the purposes of this Policy, “personal information” is any information related to an identified or identifiable natural person.

If the user engages with the Site under authority from a different party or on another party’s behalf, then “user” and “you” (and its variants, including “your,” “yours,” etc.) as used herein refers to that person on whose behalf the Site is used (e.g., an employer). If the person engaging with our Site is an individual, acting in their own individual capacity, then “user” and “you” (and its variants) refers to that individual. If you have anyone using the Site on your behalf, you agree that you are responsible for the actions and inactions of all such persons, as they were your own.

Please read this Policy carefully. You can contact us with questions using the details in the “Contact Us” section of this Policy.

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Applicability of this Policy

This Policy applies to personal information collected in connection with the Site (in each case, as defined in the Terms of Use). If you do not agree with the terms of this Policy, do not access or use the Site, or any other aspect of our business.

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What we collect 

When you interact with the Site, we and/or our service providers may collect personal information about you from different sources listed below.

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Personal information you provide to us

  • Contact Information, such as your name, email address and country information. 
  • Financial Information, such as your dYdX and/or Ethereum network address, cryptocurrency wallet IDs and other wallet information, notably by an extension of the browser, transaction history, trading data and associated fees paid. 
  • Transaction Information, such as information about the transactions you make on or through services made available on the Site, such as the type of transaction, transaction amount, and timestamp. 
  • Correspondence, such as your feedback, questionnaire and other survey responses, and information you provide to our support teams, including via our help chat or social media messaging channels. 
  • Chat (bot), the messages you write in the chat. 

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Personal information collected via automated means 

  • Online identifiers, such as username, geo-location (country), browser fingerprint, operating system, browser name and version, and IP addresses.

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Personal information we receive from third parties.

  • Personal information we receive from third parties. Sometimes, we receive personal information about you from other sources, including from our affiliates, vendors, and public databases. We may combine the information collected from these sources with the information we get from the Site for our own purposes.

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How we use information 

We will use your personal information as disclosed herein, if we have a contractual relationship or your consent or if it is in our legitimate business interest to use the personal information notably to ensure that the website can function properly, promote our services and realize statistics or if there is another lawful basis to do so. We can only rely on our legitimate business interest, if it is fair and reasonable to do so. 

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We may use your personal information to make the Site available in accordance with our Terms of Use and for:

  • Providing the Site. We may use the personal information we collect to provide, maintain, and improve the Site, including as we described in the Terms of Use. 

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  • Safety and security. We may use your personal information in our efforts to:
    • protect, investigate, and prevent against fraudulent, unauthorized, or illegal activity;
    • monitor and verify identity or service access, and combat spam, malware or security risks;
    • perform internal operations necessary to provide the Site, including to troubleshoot software bugs and operational problems;
    • enforce our agreements with third parties, and address violations of our Terms of Use or agreements for other products or Site; and
    • comply with applicable security laws and regulations.

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  • Customer support. We may use your personal information in our efforts to:
    • direct user questions to the appropriate customer support person;
    • contact you;
    • investigate and address user concerns; and
    • monitor and improve our customer support responses and processes.

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  • Research and development. We may use your personal information for testing, research, analysis, product development, and to develop new features and products relating to the Site.

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  • Legal and regulatory compliance. We may use your personal information to enforce compliance with our terms and policies, including our Terms of Use, to defend ourselves against legal claims or disputes, for identity verification purposes, to investigate or address claims or disputes relating to use of the Site, as permitted by applicable law, and as requested by regulators, government entities, or official inquiries. We also may provide your personal information to our third-party service providers, including Elliptic Enterprises Limited, to confirm whether you are on any sanctions lists, which might prohibit us from doing business with you.

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When we share and disclose information

We may share your information in the following circumstances or for any other purpose:

  • To Comply with our legal obligations. We may share your information: (a) to cooperate with government or regulatory enquiries or investigations; (b) when we are compelled to do so by a subpoena, court order, or similar legal procedure; (c) when we believe in good faith that the disclosure of personal information is necessary to prevent harm to you, us, or another person; (d) to report suspected illegal activity; or (e) to investigate violations of our Terms of Use, agreements for other products or services, or any other applicable policies.

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  • With Service Providers, vendors, partners or other third parties. We may share your personal information with service providers, vendors, partners or other third parties who need access to personal information to provide services.

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  • Affiliates. We may share your personal information with our subsidiaries and affiliates.

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  • During a change to our business. If we engage in a merger, acquisition, bankruptcy, dissolution, reorganization, sale of some or all of our assets or stock, financing, public offering of securities, acquisition of all or a portion of our business, a similar transaction or proceeding, or steps in contemplation of such activities, some or all of your personal information may be shared or transferred.

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Transfer outside the EU or adequate country 

We, our affiliates, subsidiaries, and third-party providers may process your personal information outside of your home country. 

We will employ a suitable transfer mechanism as required by applicable data protection laws and ensure that your personal information receives an adequate level of protection (e.g. Standard Contractual Clauses adopted pursuant to applicable data protection laws of the EU). 

For more information about how we transfer personal information internationally, please contact us using the details in the “Contact Us” section of this Policy.

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Data retention

We retain your personal information as long as is necessary to fulfill the purposes for which it was collected and processed, in accordance with good practices in accordance with applicable laws, or until you withdraw your consent (where applicable).

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Personal information required to establish proof of a right or contract, or to comply with a legal obligation, will be kept for the period stipulated by the law in force.

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Your rights and choices 

You may submit requests relating to the personal information that we hold about you, including requests to access, correct/update, delete, restrict the processing of, or transfer such information. Please note that, in order for us to review and respond to such requests, we will require you to verify your identity.

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You have certain data protection rights under the applicable data protection law, including the following:

  1. You have the right to access personal information we hold about you and to ask that your personal information be corrected, or (in some limited circumstances) erased.
  2. You also have the right to object to receiving direct marketing, or to request that we restrict processing.
  3. You have the right to ask us to stop processing your personal information.
  4. You have the right to be informed of a personal data breach (unless the breach is unlikely to be prejudicial to you).
  5. You have the right to have your personal information transmitted directly to another party in a portable or machine-readable format (right to data portability).
  6. You have the right to withdraw your consent for processing for which the consent is required, at any time.
  7. You have the right to file a complaint regarding our data protection practices with your relevant data protection authority. 

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  • For EU individuals

Please note that the rights described above are not all absolute and may not apply in all circumstances. For more information about your rights please refer to Chapter III of GDPR.

We will review and respond to such requests without exceeding the maximum period of one month, or in the case of a complex request, we will notify you of the additional one-month period. We may have valid legal reasons to refuse your request, and will inform you if that is the case. 

To submit such a request, contact us using the details in the “Contact Us” section of this Policy.

If you find necessary to file a complaint, you can find the relevant EU data protection authority here.

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Security

We undertake to protect the security, confidentiality and integrity of your personal information provided on the website through the use of physical and logistical security measures.

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No internet system can be completely secure. Therefore, although we take steps in an effort to secure your information, we cannot guarantee that your information, searches or other communication will always remain secure. 

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Third-party matters

Through the Site, we may provide links to websites, mobile applications or any other online assets that are not owned or controlled by us. This Policy does not apply to those websites. If you choose to use those websites, please check the legal and privacy statements posted on each website, mobile application or the online asset you access to understand their privacy practices. We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

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Changes to this Policy

Please note that we may change this Policy from time to time. If we make any changes to this Policy, we will change the last updated date above and, in some cases, we will provide further notice (for example, by publishing a statement on our website home pages or by sending you an e-mail). We encourage you to review the Policy whenever you interact with us to stay informed about our privacy practices, and to stay informed about the methods you can use to control the use of your personal information and protect your privacy.

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Cookies 

We do not use cookies or similar tracking technologies on our website.

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Contact Us

Please contact us if you have any questions about this Policy. You may contact us at info@dydxopsservices.com

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